Tag Archives: FTC

The Centre for Science in the Public Interest (CSPI) is a somewhat voracious “defender” of a healthy lifestyle. While I agree with many of their positions, I disagree with much of the way they go about it, with attacks on various foods and supplements that often go outside scientific support and verge on obsession. I think they need to remember that stressing too much about what you’re eating can be more damaging to the health than whatever it is you are actually eating!

CSPI attacks Amway over Nutrilite twist tubes, mentioning in particular two products, Nutrilite Fruit & Vegetables 2GO twist tubes and Strawberry Kiwi flavored Immunity Twist Tubes. CSPI’s letter and press release show a lack of due diligence on their part both with regards the products they attack and Amway itself, as well as, surprisingly, a lack of understanding of FDA regulations. I’ll start with their confusing, and misleading press release.

In the release they say –

“Fruits & Vegtables 2GO” has “the antioxidant equivalent of two of the 9–13 daily servings of fruits and vegetables your body needs,” according to Amway. But there’s far more to fruits and vegetables than just antioxidants, according to CSPI.

Oh the irony. CSPI is pretty much parroting Nutrilite’s greatest marketing differential back at Nutrilite to falsely criticise a Nutrilite product. Yes, CSPI, you are right. There is far more to fruits and vegetables than just antioxidants. It’s what Nutrilite has been saying for nearly 80 years. That’s why Fruits & vegetables 2GO has actual fruit and vegetables in it! A review of the ingredient label shows it includes “Acerola Cherry Concentrate … Pomegranate, Cranberry, Blueberry, Carrot, and Red Beet Juice Concentrates”. Real fruit and real vegetables, complete with all those phytochemicals CSPI correctly points out are important.

CSPI seems to have assumed that Amway’s products are like most other competitors in the nutritional supplements category – composed of synthetic isolates. In general, they’re not. That’s the Nutrilite difference. In their letter to Steve Van Andel, CSPI goes further –

Amway claims that “60mg of vitamin C from NUTRILITE Acerola Cherry Concentrate [provides] the natural vitamin C equivalent of about one mango or 1/2 cup of cooked broccoli” and “5 mg of Beta carotene from the algae plant [provides] the natural beta carotene equivalent of about one medium carrot or one cupe of cataloupe.” These claims suggest that the ingestion of isolate vitamins or antioxidants have the same benefit as the ingestion of whole foods such as mango, broccoli, carrots, or cataloupe that countain those vitamins and antioxidants. This is not the case, and suggesting as much is deceptive to consumers.

CSPI has somehow come to the conclusion that “Nutrilite Acerola Cherry Concentrate” is somehow an “isolated vitamin”. It’s not. It’s exactly what it says, Acerola Cherry Concentrate. Amway also clearly states that it’s natural beta carotene, from algae, provides the equivalentbeta carotene as a carrot or some cantaloupe. “equivalent” is not “the same“. A cup of cantaloupe is not the same as a medium carrot is not the same as some algae. Contrary to CSPI’s claims, Amway nowhere suggests they are, and I can’t see how this is at all “deceptive to consumers”

Now, the Strawberry/Kiwi flavored immunity twist tube is one of those exceptions from “the Nutrilite difference”. It doesn’t contain fruit and vegetables as nutritional sources, it’s primarily Vitamin C as ascorbic acid (almost certainly synthetic). Personally I, and others who contribute to this blog and Amway Talk, were a little bit disappointed in the twist tube products when they came out, because they didn’t uphold the Nutrilite difference. The Fruit & Vegetables 2GO product, released fairly recently, begins to address that. Still, CSPI’s criticisms of this product verge on the childish. Despite the very name of the product saying it’s “Strawberry and Kiwi flavored dietary supplement”, CSPI apparently believes the pictures of a kiwi and a strawberry on the front misleads consumers in to thinking it has actual fruit in it. That might be true if you were already aware of the normal Nutrilite approach, but for the vast majority of consumers – really? A can of fanta has a picture of an orange on the front. Do people really believe it contains oranges? Pictures of fruit on packaging are an extremely common approach for depicting the flavor of a product. Is CSPI going to threaten to sue them all?

CSPI also criticises this product for the claim that it is a an “immune system booster” that will “protect your cells.” CSPI believes this claim is deceptive as it implies it prevents or cures disease – a no no under FDA rules. They’re wrong. This is what are categorised by the FDA as “structure/function” claim, not a disease claim. The idea that antioxidants are import in protecting cells and the immune system is well established, I believe Amway is on safe ground on this issue.

There is one area where I think CSPI is correct in their criticism. They state – “Also, both product lines contain the artificial sweetener sucralose, despite a print advertisement for “fruits & vegetables 2GO” that claims the product has no artificial ingredients.”

Both products state on their packages and on the Amway website that they contain “no artificial colors or flavors”. This is correct. Personally I think this kind of marketing line does verge on deceptive as many people would interpret it as “nothing artificial” rather than just limited to colors or flavors. Sucralose is neither a color or flavor so Amway is technically and legally correct. However, CSPI also refers to a print advertisement (pictured right) for Fruit & Vegetables 2GO which states the product “contains no artifical colors, flavors, preservatives or ingredients“. This is clearly wrong, it contains sucralose, which is an artificial ingredient.

So CSPI gets one claim right out of the many they make against Amway. Their letter to Steve Van Andel though, I find extremely ironic, with several pages devoted to educating him about the benefits of phytochemicals, a consumer field Amway and Nutrilite virtually pioneered!

This was originally posted back on August 9, 2007, however it got buried in events later that day and Part II was never written. A few folk have suggested the topic is worth revisiting, so here it is! Some changes, such as shipping cost changes in the US and the whole new setup in the UK mean not everything is as relevant to all markets and applicable as when originally written, but most still is.

I’ve been pondering for some time what kind of changes could be made to the Amway and Quixtar business opportunities to make them better. Amway and Quixtar have been pondering the same thing, and on the Opportunity Zone blogs have been asking IBOs for their input.

I believe that “improvement” needs to be addressed in three different arenas –

improvements that can be made related to consumers (of which IBOs are a part) such as addressing product pricing and shipping costs.

improvements that can be made related to training, and part of that is to do with BSM and BSM suppliers

improvements that can be made related to reputation

Obviously these areas overlap somewhat and in this post I’m going to talk about a simple change that could dramatically improve reputation, yet change very little at all. What’s the change?

As many North American readers would know, in 2006 the US Federal Trade Commission (FTC) proposed a new Business Opportunity Rule which, as written, would require multi-level marketing opportunity promoters to provide prospects with a whole range of new information, such as names of other local participants, lawsuits, etc etc etc. It also imposed a mandatory 7-day waiting period before a person could join.

There is some very interesting information in the full FTC discussion paper. One area of discussion was the problem of declaring average incomes, when many people join purely for the purpose of receiving “wholesale pricing”. Shaklee for example, revealed that 85% of folk who join that company do so for that reason.

The FTC included summaries of the claims of the bogus “consumer advocates” Pyramid Scheme Alert (Robert FitzPatrick) and Consumer Awareness Institute (Jon Taylor) but appeared unswayed by their arguments that MLM are effectively all illegal pyramids. One particular line from the Jon Taylor’s CAI which always makes me laugh –

“[i]t is extremely rare for MLM victims to recognize the fraud in an MLM program without intensive de-programming by a knowledgeable consumer advocate”

Good grief, get a life Jon.

Folk have argued that the UK BERR and the FTC have recently been in regular contact regarding MLMs. In particular a number of critics have claimed the BERR case has put MLM, and in particular, Amway, under strong FTC scrutiny. If this paper is any reflection of what the FTC and BERR have discussed, then it augurs well for that case.

Many critics like to claim that Amway and other MLMs are a “product based illegal pyramid scheme”. The claim is that they are illegal pyramid schemes because the majority of products are consumed by “members of the scheme” and not retail customers. It’s quite common for them to also claim that in the FTC vs Amway, the FTC declared Amway not an illegal pyramid scheme because of these retail customers. Continue reading MYTH: It’s a pyramid if most products are bought by IBOs→

Is it dishonesty or just ignorance? If you search around the posts of critics of Amway and Quixtar on the internet, something you’ll see regularly is reference to something like “The 70% Retail Sales Rule”.

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Thanks for visiting! This site is my personal opinions about the Amway company. I've been researching, blogging and commenting on Amway and Multilevel Marketing for more than a decade.
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